Chapter 2 Vendor Compliance
Transcript of Chapter 2 Vendor Compliance
Chapter 2
Vendor Compliance (Apparel & Accessories)
I. Supplier Code of Conduct ......................................................................................................................... 3
II. Supply Chain Social Responsibility Overview .......................................................................................... 5
a. Monitoring Factory Working Conditions ............................................................................................. 5 b. Transparency and Continuous Improvement ................................................................................... 6
III. Factory Ratings ............................................................................................................................................ 7
a. Overview ................................................................................................................................................ 8 b. Proposed Factories ............................................................................................................................... 8 c. Active Factories .................................................................................................................................... 8 d. Audits through Buying Agents ............................................................................................................. 9 e. Third Party Audits ................................................................................................................................... 9 f. Direct .................................................................................................................................................... 10 g. U.S. Based Vendors ............................................................................................................................. 10 h. Better Work Policy ............................................................................................................................... 10
IV. Customs and Trade Partnership Against Terrorism (C-TPAT) Overview ............................................... 11
V. C-TPAT Compliance Criteria .................................................................................................................... 12
a. Business Partner Requirements .......................................................................................................... 12 b. Container Security .............................................................................................................................. 12 c. Physical Access Controls ................................................................................................................... 15 d. Personnel Security ............................................................................................................................... 17 e. Procedural Security ............................................................................................................................ 19 f. Security Training and Threat Awareness .......................................................................................... 19 g. Physical Security ................................................................................................................................. 19 h. Information Technology Security ...................................................................................................... 20
VI. C-TPAT Factory Audits & Rating System .................................................................................................. 22
a. Proposed Factories ............................................................................................................................. 22 b. Active Factories .................................................................................................................................. 22 c. Direct Vendors ..................................................................................................................................... 22 d. U.S. Based Vendors ............................................................................................................................. 23
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VII. Chapter 2A – Talbots Supplemental Guidelines ...................................................................................... 1
a. Introduction .................................................................................................................................................. 1
b. Supplemental Guidelines - Compliance with Talbots’ Supplier Code of Conduct ............................. 2
c. Policies and Procedures ............................................................................................................................. 3
d. Child Labor ................................................................................................................................................... 4
e. Forced Labor ................................................................................................................................................ 5
f. Foreign Contract Workers ........................................................................................................................... 7
g. Discrimination .............................................................................................................................................. 9
h. Freedom of Association ............................................................................................................................ 10
i. Harassment and Abuse ............................................................................................................................ 11
j. Health and Safety ...................................................................................................................................... 12
k. Working Hours ............................................................................................................................................ 16
l. Wages and Benefits ................................................................................................................................... 17
m. Subcontracting .......................................................................................................................................... 19
n. Environmental Practices ........................................................................................................................... 20
o. Business Integrity ....................................................................................................................................... 21
p. Sanctions .................................................................................................................................................... 22
q. Anti-Money Laundering ............................................................................................................................ 24
APPENDIX A: DEFINITIONS ............................................................................................................................... 25
APPENDIX B: POCKET GUIDE TO CHEMICAL HAZARDS ................................................................................. 27
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I. Supplier Code of Conduct
Talbots’ Code of Conduct is based on internationally recognized human rights and
business practice standards. Detailed Standards and Expectations can be found in the
Supplemental Guidelines at the end of this chapter.
No Child Labor
Suppliers must comply with the minimum employment age and minimum compulsory education level defined by
national law or the International Labor Organization (not less than 15 years of age, subject to exceptions allowed by the
ILO and national law), whichever is higher. Suppliers must obey all legal requirements for work of authorized minors,
particularly those pertaining to hours of work, wages, minimum education, and working conditions.
No Forced Labor
Suppliers must not use any type of forced or involuntary labor, whether prison, indentured, bonded, or other compulsory
labor, and must ensure there is no forced labor or human trafficking in their supply chains.
No Discrimination
Discrimination in employment, including hiring, pay, benefits, job assignments, working conditions, training, recruitment,
promotion, discipline, termination, and retirement, on the basis of gender, race, religion, age, disability, sexual
orientation, gender identity, parental status, pregnancy, nationality, political opinion, and social or ethnic origin is
prohibited.
Respect for Freedom of Association
Suppliers must recognize and respect the rights of employees to lawfully associate and to bargain collectively. Suppliers
may not interfere with, obstruct, or prevent legitimate related activities, and must ensure workers are not intimidated,
harassed, or penalized for the non-violent exercise of their right to join or refrain from joining any organization.
No Harassment or Abuse
All workers must be treated with dignity and respect. No worker may be subjected to physical, sexual, psychological, or
other forms of mental or physical coercion, harassment, abuse or intimidation. Suppliers are expected to implement
reasonable procedures for disciplining and/or terminating workers and maintain documentation to demonstrate
compliance. The use of fines as a disciplinary practice is prohibited.
Health and Safety
Conditions in all production facilities must be safe, clean, healthy, and consistent with all applicable laws, regulations,
and supplemental guidelines of this Code, to avoid preventable work-related accidents and injuries. Supplier-provided
employee housing, bathing, and toilet facilities must be safe, clean, and adequate to the number of employees. Where
higher than the law or the Code requirement, suppliers should implement industry best practices.
Working Hours
All work must be voluntary, without threat of penalty, punishment, or dismissal. Workers must not be required to work
more than 60 hours per week (inclusive of overtime), or more than the regular and overtime hours allowed under local
law, on a regularly scheduled basis. Workers are entitled to at least one day off in every seven-day period.
Wages and Benefits
Suppliers must comply with the minimum wages and benefits required by local law or the local industry standard,
whichever is higher. Workers must be paid for overtime hours at the premium rate legally required in the country of
manufacture. In those countries where overtime compensation laws do not exist, employees must be compensated at
least equal to their hourly compensation rate.
No Unauthorized Subcontracting
Suppliers may not subcontract any operation in the manufacturing process without prior written consent from Talbots,
and only after the subcontractor has agreed to comply with Talbots’ Code of Conduc
Environmental Practices
Suppliers may not subcontract any operation in the manufacturing process without prior written consent from Talbots,
and only after the subcontractor has agreed to comply with Talbots’ Code of Conduct.
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Sanctions
Suppliers must not cause Talbots to violate U.S. and other applicable economic sanctions laws and regulations
(collectively, “Sanctions”), which are laws and regulations that restrict business with certain countries, individuals, and
entities in order to advance specific foreign policy and national security priorities.
Anti- Money Laundering
Suppliers must not cause Talbots to violate applicable anti-money laundering laws and regulations, including the
Currency and Foreign Transactions Reporting Act of 1970 (commonly referred to as the “Bank Secrecy Act”), as
amended by the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct
Terrorism Act of 2001 (commonly referred to as the “USA PATRIOT Act”) (all such laws, collectively, “AML Laws”).
Business Integrity
Suppliers must comply fully with the applicable laws and regulations of the countries in which they operate. In addition,
business must be carried out ethically, honestly, and fairly. Suppliers must not, directly or indirectly, make any improper or
unlawful gifts or payments to any person, entity, or government official in connection with accepting or performing
orders for Talbots, or in an attempt to impact the objectivity of third party representatives appointed by Talbots to carry
out inspections and compliance audits.
Where the Code requirements are stricter than the law, compliance with the Code is required.
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II. Supply Chain Social Responsibility Overview
Talbots has a long-standing heritage of high quality and uncompromising ethics. Our commitment
to responsible business practices includes treating the workers who make our products with
dignity and respect. Our Code of Conduct establishes standards for all of our suppliers, and in our
Supplemental Guidelines to Talbots’ Supplier Code of Conduct, we provide detailed and
practical guidance about our expectations, informing our suppliers, contractors, vendors, and
agents of the employment practices and working conditions that comprise the minimum
standards for doing business with Talbots.
This chapter outlines the tenets of our social responsibility expectations and Talbots’ supply chain
responsibility program.
a. Monitoring Factory Working Conditions
The Talbots factory social responsibility program is designed to increase Talbots’ awareness
about supply chain risks, identify areas in need of improvement, and engage with its suppliers
on working conditions.
Working conditions are an important aspect of Talbots’ assessment of overall factory
performance. Talbots’ ability to fulfill its commitment to responsible business practices requires
visibility into working conditions at all factories and all sub-contractors producing for Talbots.
As a measure and means of driving improvement in our supply chain, Talbots maintains a
program of regular social compliance audits. This includes initial compliance assessments for
the factories proposed for Talbots’ production, and regular evaluations of active suppliers, on
an announced or unannounced basis. Talbots utilizes buying agent and third-party
(unaffiliated) monitors to conduct on-site evaluations and inspections of its vendors’ and
factories’ facilities.
Talbots relies on social compliance audits conducted by its nominated audit partners for
visibility into factory working conditions. Talbots uses the results of social audits to evaluate
and rate factory working conditions according to the relevant laws and regulations and the
Talbots Code. These ratings help inform sourcing decisions. The aim of Talbots’ evaluations
and rating system is to identify problems, establish root causes, and outline appropriate steps
to achieve legal compliance and continuous, sustainable improvement. Violations or non-
compliances with the Code and/or law will be reported to the supplier for follow up and
corrective action. Talbots will monitor supplier progress toward compliance, usually by
holding management accountable to an agreed-upon corrective action plan.
Where there are egregious violations, such as child labor, forced or prison labor, bribery,
physical abuse, and/or the supplier does not demonstrate a willingness to comply, Talbots
may discontinue business with the supplier. Talbots reserves the right to make periodic
updates to its Code of Conduct and social responsibility program; we will notify vendors and
factories of any such changes.
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b. Transparency and Continuous Improvement
As a condition of doing business with Talbots, we expect suppliers to provide accurate
information and, during audits, to provide full access to the facility, workers, and records, as
well as dormitories. We expect our suppliers to openly and honestly discuss any non-
compliance issue and the underlying business challenges with Talbots or our representatives.
When violations are identified, Talbots requires vendors and associated factories to make a
sincere effort toward improvement of working conditions.
Talbots is aware that social compliance audits provide only a snapshot of factory working
conditions, and evaluations will always be somewhat subjective. We therefore seek to
cultivate transparent business relationships with suppliers committed to respect for workers,
continuous improvement in working conditions, and to build the mutual confidence necessary
to raise concerns with each other.
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III. Factory Ratings
Talbots uses audits to assess supplier factories’ compliance with the standards described in The
Talbots Inc. Supplier Code of Conduct. Audit findings are input into Talbots Factory Rating Tool,
which calculates numerical factory ratings on a scale from 0 (worst score) to 100 (best score).
Based on audit findings and other information, Talbots will assign factories an overall social
compliance rating, using a “traffic light” color rating scale.
Talbots audit tool allows us to gauge relative performance comparing one or different factories
over time. Talbots’ factory rating system takes continuous improvement, as well as persistent
problems, into account. The audit tool rewards factories that show improvements in successive
audits – even if full compliance is not achieved – but increases deductions for repeat violations.
Each audit begins with a perfect rating of 100, or “Green;” points are deducted according to
severity and frequency of non-compliance with the Code. Where appropriate, Talbots may add
points for factories implementing best practices in managing working conditions.
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a. Overview
All suppliers must agree to and/or facilitate compliance assessments of any factories
proposed for or used for Talbots production. Talbots reserves the right to conduct
unannounced audits of approved factories at any time. Factories that manufacture goods
for Talbots must allow Talbots representatives or third parties authorized by Talbots unrestricted
access to their facilities at all times, whether or not the factory is notified in advance.
Factories cannot be made active, or purchase orders written, if minimum working conditions
standards are not met. Once approved, all suppliers producing for Talbots are required to
abide by the Supplier Code of Conduct and all applicable laws and regulations. Acceptance
of Talbots PO/PM and shipment of merchandise to Talbots represent a continuing affirmation
of compliance.
On-site social compliance inspections may include, but will not be limited to:
• Interviews with employees, on or off-site
• Review of relevant records, documents, and bookkeeping, including production records
• Inspections of employee files, including time cards and wage statements
Social audits will be conducted at least once annually at all active factories to verify
compliance.
b. Proposed Factories
As part of the new factory on-boarding process, all factories under consideration for Talbots
production will undergo an initial social responsibility audit, either by Talbots’ nominated
auditing partners or Talbots’ agents.
If the proposed factory receives an unacceptable rating or a zero tolerance violation is
found, it will not be approved for production, but may have the opportunity to improve its
rating through corrective actions and subsequent follow-up audits to ensure violations have
been satisfactorily addressed.
c. Active Factories
All Talbots-approved factories remain active for production for a specific time period
determined by the factory’s social compliance rating. Talbots will communicate the length of
a factory’s active status after each audit. Before the conclusion of the active period, if
Talbots wishes to continue working with the factory, it will be re-assessed for social
compliance.
All factories that are approved for Talbots’ production will be audited by Talbots audit
partners at least once per year, with the exception of “Green”-rated factories, which can
remain active for up to 18 months.
If an approved factory receives a rating of dark orange or red, Talbots will consider this
factory “high risk,” with follow up determined on a case-by-case basis. At the least, Talbots
and/or its buying agent will work with factory management to ensure a clear plan for
corrective action is in place. If the factory fails to improve its social compliance rating to
within a specified time period, Talbots may recommend resources to help factory
management identify the root causes of non-compliance and building the proper
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management systems to avoid repeated non-compliance. However, repeated failure to
make progress will result in revocation of approval as a Talbots’ production factory.
Talbots will review audit reports and determine the need to re-audit on a case-by-case basis.
The list below is not exhaustive but is representative of the most common reasons for re-audit
requests:
• There is alleged abuse of acceptable working hours or weekly rest
• There are alleged inadequacies in wages, overtime pay, or benefits
• Working conditions are dangerous or inhumane
A timeline for completion will be developed in consultation with the factory, vendor, and/or
Talbots’ agents. Reevaluation will occur sometime after the corrective action timeline is up,
and Talbots may require re-audits to be vendor-paid.
Talbots may prohibit or terminate business with any vendor or factory that:
• Has severely violated the Supplier Code of Conduct or any local law (i.e., underage or
forced labor)
• Is unable or unwilling to address initial audit findings
• Continues to be non-compliant after attempting to address re-audit findings
In the event of termination of business as a result of observed egregious Code violations and
termination causes orders to be cancelled, Talbots will not be responsible for any ensuing
liability related to order cancellation.
Following is detailed information about Talbots’ factory audit program by type of supplier.
d. Audits through Buying Agents
Talbots works with many vendors through a buying agent. Vendors and factories should
consider buying agent’s representatives as part of Talbots’ staff and treat them as such.
Where possible, the buying agent’s social compliance team will conduct initial social
compliance audits and annual factory social compliance audits on behalf of Talbots and
provide Talbots with audit findings. Vendor and factory management are expected to
review audit findings and agree to any corrective action recommendations that result from
the factory audit. At the conclusion of the audit, factory management is expected to agree
to an appropriate course of action for each finding, as well as to a time frame in these will be
completed. To reduce the incidence of duplicative corrective action plans, Talbots will
consult with its agents, vendors, or other brands, as appropriate, to determine its involvement
with the implementation process.
e. Third Party Audits
Talbots will use a third-party audit firm to perform independent audit verification and
additional social audit services on its behalf, particularly when working through U.S.-based
vendors, pursuing orders with direct vendors, and as due diligence to verify agent audits.
Vendor and factory management must to accommodate third-party auditors’ requests. Third
party auditors will leave behind preliminary corrective action plans, and Talbots will follow up
with the agent, vendor, or factory to determine next steps and implementation.
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f. Direct
When Talbots plans to import directly from overseas vendors, a third-party audit firm will
conduct vendor-prepaid annual social audits on Talbots’ behalf. The third-party auditors will
prepare a preliminary corrective action plan, which vendor and factory management are
expected to agree to; Talbots will review the audit and determine the need for any additional
follow up.
g. U.S. Based Vendors
In cases where Talbots sources product from a U.S.-based vendor, Talbots may waive initial
social compliance audits for factory on-boarding (usually limited to overseas non-apparel
factories]. Talbots requires the U.S.-based vendor to provide completed copies of the factory
self-assessment form. This form may be accompanied by (but not substituted by) evidence of
improvements made under another corrective action plan for another entity.
Talbots Factory Self Assessment Form.pdf
Audit Fatigue
Talbots recognizes that factories often undergo multiple ethical audits and corrective action
plans each year. To minimize duplicative audit activity, Talbots will, on a case-by-case basis,
accept social audits conducted on behalf of other retailers, provided:
• Audit was conducted according to the ETI Base Code (Sedex format);
• Audit was conducted within the last 9 months;
• Audit was conducted by an independent audit company, such as Intertek, SGS, STR, BV,
Verite, or Elevate;
• Supplier includes the completed corrective action plan resulting from the audit.
Even if Talbots waives an initial independent social compliance evaluation, Talbots
reserves the right to require an audit of any proposed factory by a Talbots-approved
independent auditor at any time. Talbots also requires annual factory evaluations
for U.S. based vendors.
h. Better Work Policy
Talbots strongly supports the ILO-IFC BetterFactories/BetterWork program, and encourages its
suppliers to participate in the program. To that end, Talbots will accept evidence of active
participation in a Better Factories or Better Work program in lieu of initial social compliance
audit as well as annual factory audits. As often as possible, Talbots will seek a Better Work
buyer subscription for participating factories producing for Talbots.
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IV. Customs and Trade Partnership Against Terrorism (C-TPAT) Overview
C-TPAT is a joint effort program between U.S. Customs and Border Protection (CBP), a division of
United States Department of Homeland Security (DHS), and the trade community, to reduce the
threat of terrorism by means of protecting the integrity of cargo imported into the United
States. This effort requires building cooperative relationships to strengthen the entire supply chain.
Talbots seeks to operate with the highest ethical standards in every aspect of our business,
including our supply chain operations. We expect vendors and factories with whom we partner
to also hold themselves to these high standards and to act with integrity, transparency,
accountability, and mutual respect.
Talbots is an active, re-validated participant in the C-TPAT program. We fully support the program
and are highly compliant.
Talbots reserves the right to suspend, discontinue, or terminate its relationship with any vendor or
factory that violates this C-TPAT Compliance Criteria, or any applicable law.
Talbots also reserves the right to make periodic updates to this C-TPAT Compliance Criteria and
will notify its vendors and factories of any such changes.
The following content outlines the tenets of our C-TPAT expectations and Talbots’ Compliance
Program.
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V. C-TPAT Compliance Criteria
a. Business Partner Requirements
Talbots requires that all vendors and suppliers meet and/or exceed the minimum criteria
outlined in the C-TPAT Foreign Manufacturers Security Criteria as posted on CBP website:
http://www.cbp.gov/border-security/ports-entry/cargo-security/ctpat/security-
guidelines/foreign-manufacturers
We expect suppliers producing Talbots merchandise to embrace and comply with these
standards, but also expect continuous improvement to secure the entire global supply
chain. Vendors and suppliers must abide by all local law. In the event that local law and this
C-TPAT Compliance Criteria are in conflict, the stricter standard shall apply.
Suppliers must develop security processes and procedures consistent with the C-TPAT
Compliance Criteria, including written and verifiable processes for selection of their carriers,
manufacturers, suppliers and vendors. Periodic reviews of these suppliers’ processes and
facilities will be conducted based on risk.
Talbots will annually request information and documentation from all vendors and suppliers
regarding security compliance criteria. All information will remain confidential. Further, Talbots
will not disclose identity of the supplier without the supplier’s consent, or at the request of CBP.
• Annual Vendor Security Certification
• Supplier Security Letter (container and seal inspection reports included)
• Supplier Security Self-Assessment
Vendors and/or Suppliers who have obtained a certification in a supply chain security
program being administered by Foreign Customs Administration are required to indicate their
status of participation to Talbots’ Customs Compliance team.
b. Container Security
Container integrity must be maintained to protect against the introduction of unauthorized
material and/or persons throughout the entire supply chain. Procedures must be in place to
ensure integrity is not compromised during storage, loading, and sealing of container.
Container Inspection
Physical integrity of the container structure and reliability of its locking mechanism must be
verified prior to stuffing. The below 7-point container inspection is required for all factory
loaded containers.
1. Front Wall
2. Left Side
3. Right Side
4. Floor
5. Ceiling/Roof
6. Inside/Outside Doors, Including Locking Mechanism
7. Outside/Undercarriage
Any container with integrity found to be deficient or questionable must be rejected.
All containers must be measured to include interior length, width and height. The following
information contains detailed specifications. (Source: www.apl.com)
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Description Metric U.S.
Cubic Capacity 33.200 Cubic Meters 1,170 Cubic Feet
Payload (Weight) 21,850 kg – 28,160 kg 48,171 lb – 62,082 lb
Tare Weight 2,150 kg – 2,220 kg 4,740 lb – 4,894 lb
Max Gross Weight 24,000 kg – 30,480 kg 52,911 lb – 67,197 lb
Internal Length 5.898 m 19’4”
Internal Width 2.352 m 7’9”
Internal Height 2.392 m 7’10”
External Length 6.058 m 19’10 ½ ”
External Width 2.438 m 8’0”
External Height 2.591 m 8’6”
Door Opening Width 2.340 m 7’8”
Door Opening Height 2.280 m 7’6”
Lashing Rings • Five on each top and bottom rails, capacity 2,000 kg
• Three on each corner post, capacity 1,500 kg
Description Metric U.S.
Cubic Capacity 67.700 Cubic Meters 2,391 Cubic Feet
Payload (Weight) 26,760 kg – 28,760 kg 58,996 lb – 63,405 lb
Tare Weight 3,720 kg – 3,740 kg 8,201 lb – 8,245 lb
Max Gross Weight 30,480 kg – 32,500 kg 67,197 lb – 71,650 lb
Internal Length 12.032 m 39’6”
Internal Width 2.352 m 7’9”
Internal Height 2.392 m 7’10”
External Length 12.192 m 40’0”
External Width 2.438 m 8’0”
External Height 2.591 m 8’6”
Door Opening Width 2.340 m 7’8”
Door Opening Height 2.280 m 7’6”
Lashing Rings • Ten on each top and bottom rails, capacity 2,000 kg
20’ Standard Steel Container
40’ Standard Steel Container
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• Three on each corner post, capacity 1,500 kg
Description Metric U.S.
Cubic Capacity 76.400 Cubic Meters 2,700 Cubic Feet
Payload (Weight) 26,750 kg – 28,550 kg 58,974 lb – 62,942 lb
Tare Weight 3,730 kg – 3,950 kg 8,223 lb – 8,708 lb
Max Gross Weight 30,480 kg – 32,500 kg 67,197 lb – 71,650 lb
Internal Length 12.033 m 39’6”
Internal Width 2.352 m 7’9”
Internal Height 2.698 m 8’10”
External Length 12.192 m 40’0”
External Width 2.438 m 8’0”
External Height 2.896 m 9’6”
Door Opening Width 2.340 m 7’8”
Door Opening Height 2.585 m 8’6”
Lashing Rings • Ten on each top and bottom rails, capacity 2,000 kg
• Three on each corner post, capacity 1,500 kg
Description Metric U.S.
Cubic Capacity 86.500 Cubic Meters 3,055 Cubic Feet
Payload (Weight) 28,280 kg 62,350 lb
Tare Weight 4,740 kg 10,450 lb
Max Gross Weight 33,020 kg 72,800 lb
Internal Length 13.556 m 44’6”
Internal Width 2.352 m 7’9”
Internal Height 2.701 m 8’10”
External Length 13.716 m 45’0”
External Width 2.438 m 8’0”
External Height 2.896 m 9’6”
Door Opening Width 2.340 m 7’8”
40’ High Cube Steel Container
45’ High Cube Steel Container
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Door Opening Height 2.588 m 8’6”
Lashing Rings • Twelve on each top and bottom rails, capacity 2,000 kg
• Three on each corner post, capacity 1,500 kg
The outside and undercarriage must be inspected before entering your facility.
Undercarriage support beams must be visible from the outside. All seven points must be
inspected for unusual repairs. Repairs should be visible from both the inside and outside of a
container. Tap on walls, ceilings, doors and floors to listen for hollow sounds. Blocks and vents
should be visible on the inside of the container near the front wall.
Container Seals
All foreign vendors and factories (who manufacture quantities large enough to load a full
container), must have written and verifiable procedures stipulating how seals are controlled,
affixed and verified. These written procedures must include steps for recognizing and
reporting compromised seals and reporting to CBP or the appropriate foreign authority. Only
designated employees should distribute container seals for integrity purposes.
All seals must be high security seals that meet or exceed current PAS ISO17712 standards. All
containers transiting via mini-land bridge (MLB) service through the west coast must have a
‘Barrier Seal Model # MS-BAR11 with cable’ also affixed to the container. Talbots Freight
Forwarder will distribute as necessary.
Seals are required for both factory-loaded full containers and less than full container truck
shipments moving from factory to consolidator.
Talbots Container and Seal Inspection Reports must be completed by the party loading the
sea container and affixing the seal. The reports must be maintained by the party loading the
container and affixing the seal. Copies of the reports must be turned over to Talbots freight
forwarder with all commercial documents.
Container Storage
All containers must be stored in a secure area to prevent unauthorized access and/or
manipulation. Written and verifiable procedures must be in place for preventing and
reporting unauthorized entry into containers or container storage areas.
• All containers and trailers that remain at the warehouse overnight should be secured
• Containers loaded with cargo should be sealed, with seal number recorded and verified
• Identification of driver should be verified before cargo is released into their possession
• Truck drivers must have appointments and supervised when picking up containers from
the facility
c. Physical Access Controls
Access controls are instrumental in stopping unauthorized entry to facilities, maintaining
control of employees and visitors, and protecting company assets. Where possible, entrance
to facilities must be restricted to one office and one warehouse door. Entrances must be
monitored to ensure positive identification of all employees, visitors and vendors.
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Employees
• Identification (ID) badges must be issued to all employees; badges visibly worn at all times
• Access to warehouses/storage areas must be restricted to designated employees
• ID badges must to be issued and strictly controlled by security
• Procedures for the issuance, removal and changing of access devices (e.g. keys, key
cards, etc.) must be documented
• No employee must be allowed to stay in the office or facilities after the working hours
unless permission is granted by company management
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Visitors Controls
• Visitors must present photo ID upon arrival for documentation purposes
• Visitors must sign in visitors’ log upon arrival and sign out upon departure; the logbook must
include visitors name, visiting date, visiting purpose, and arrival/departure time
• A “Visitor Badge” must be issued to all visitors and must be visibly worn at all times
• Visitor badges must be temporary and different color from employee badges for easier
identification
• Visitors must be escorted at all times within company premises
Challenging and Removing Unauthorized Persons
• Written procedures must be in place to train company employees to identify and
challenge the unauthorized visitors
• Unauthorized visitors should be reported to the company security immediately
• The local police should be informed if necessary
Deliveries (Including Mail)
• Proper vendor ID and/or photo identification must be presented for documentation
purpose upon arrival by all vendors
• Arriving packages and mail should be periodically screened before being disseminated
Building Security
• Access controls must include positive identification of all employees, visitors, and vendors
at all points of entry
• Access controls to prevent unauthorized entry to facilities
• Procedures enforced to maintain control of employees / visitors to protect company assets
• Employees must be familiar with all vendors entering the facility
• Facility must have communication process in place to contact internal security personal or
local law enforcement police in the event of an emergency
d. Personnel Security
Implementing personnel security measures is an important step in securing the supply chain.
Consistent with local laws and regulations, Talbots expects all vendors and factories to screen
prospective employees prior to employment and periodically check current employees to
ensure no risk to our supply chain.
Pre-Employment Verification
• The information provided on job applications such as employment history and references
must be verified prior to employment
• Criminal history of each job applicant must be verified with local police where allowed by
local laws
Background Checks/Investigations
• Consistent with local regulations, background checks and investigations should be
conducted on prospective employees
• Current employees should be checked and reinvestigated where deemed necessary
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Personnel Termination Procedures
• Upon dismissal, employee’s ID badge must be immediately obtained and destroyed
• Access to the facility and information systems access must be blocked (i.e. facility keys
must be seized)
• Current employees should be notified of the departure of any employee
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e. Procedural Security
Security measures must be in place to protect the integrity and security of processes relevant
to the transportation, handling and storage of cargo in the supply chain.
Documentation Processing
• All relevant information used for clearing customs must be legible, complete, accurate,
and protected against the exchange, loss or introduction of erroneous information
• Computer access must be controlled by password protection; employees must be
instructed not to share their passwords with others
Manifesting Procedures
• To ensure the cargo integrity, information received from business partners must be reported
timely and accurately
Shipping and Receiving
• Export cargo should be reconciled against information on the cargo manifest before
leaving manufacturer’s premises; cargo should be accurately described, and the weights,
labels, marks and piece count indicated and verified
• Export cargo should be verified against Talbots purchase orders
• All cargo received must be counted, weighed and matched against the bill of lading
• Drivers, delivering cargo or picking up containers, must be positively identified prior to
being admitted into premises; driver’s name, driver’s company and vehicle registration
must be verified and logged
• Departure Time of the cargo from manufacturer’s warehouse and Arrival Time of the cargo
at the Container Yard or the CFS must be recorded; if delivery time exceeds allowed time
range, the trucking company and driver must be questioned
Cargo Discrepancies
• Cargo shortages, overages, and other significant discrepancies or anomalies must be
investigated and resolved. Local law enforcement authorities should be notified if an
illegal or suspicious activity is noticed.
f. Security Training and Threat Awareness
Threat awareness programs must be established to recognize and foster awareness against
any threats posed by terrorists at each point in the supply chain.
• All employees must be informed of procedures in place for situations and how to report it
• Training should be provided to employees in the shipping and receiving areas, as well as
those receiving and opening mail
• Specific training should be offered to assist employees in maintaining cargo integrity,
recognizing internal conspiracies and protecting access controls – incentives should be
offered for active employee participation
g. Physical Security
Cargo handling and storage facilities must have physical barriers and deterrents, such as
locked doors to prevent unauthorized access.
Fencing
• All cargo handling and storage facilities must be surrounded by perimeter fencing
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• Interior fencing should be used to segregate domestic, international, high value, and
hazardous cargo
• All fencing must be inspected periodically for integrity and damage
Gates and Gate Houses
• Entrance/exit gates through for vehicles and/or personnel must be manned and monitored
• Gates must be secured after working hours to prevent unauthorized access
• Number of gates should be kept to the necessary minimum for proper access and safety
• There must be a formal process in place for documenting visitors
Parking
• Employee and visitors parking spaces must be separate and marked
• Employee parking must be separate from the dock and cargo operations.
• Private passenger vehicles should be prohibited from parking in or adjacent to cargo
handling and storage areas to prevent unauthorized access
Building Structure
• Premises must be constructed of materials that resist unlawful entry (i.e. walls must be built
with concrete material and gates must be built with steel material)
• Premises must be periodically inspected and repaired, if necessary, to ensure constant
security
• Clear zones must be maintained internally and externally to monitor the security of the
facility; brush and growth should be cleared at least 35 feet from perimeter barrier
Locking Devices and Key Control
• All external and internal windows, gates. and fences must be secured with locking devices
• Management or security must control access and the issuance of all locks and keys
Lighting
• All entrances, exits, cargo handling, storage areas, fence lines, and parking areas must
have adequate lighting
• All corners of parking lots must be illuminated at night
• Flood lighting on loading and unloading areas
• Dock doors should be illuminated at night
Alarm Systems and CCTV Cameras
Security alarm systems and CCTV cameras should be utilized to monitor the premises and to
prevent unauthorized access to cargo handling and storage areas. Record retention for
CCTV recordings is a minimum of 90 days.
h. Information Technology Security
Password Protection
• Information systems must be based on individually assigned accounts and passwords must
be changed periodically
• IT security policies, procedures and standards must be in place and easily accessible by all
employees
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Accountability
• A system must be in place to identify the abuse of IT including improper access, tampering
or the altering of business data
• Any illegal access attempt from third parties must be prohibited by installing and
maintaining firewalls, anti-spyware or other security software on each PC
• All system violators must be subject to appropriate disciplinary actions for abuse
• All backup data should be stored at an off-site location
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VI. C-TPAT Factory Audits & Rating System
Talbots must have visibility into the security procedures at all Talbots producing factories and at all
potential new factories. Vendors must allow initial security assessments of all factories proposed
for Talbots’ production.
Approved suppliers are required to adhere to the C-TPAT Security Criteria and all applicable local
laws and regulations. Talbots reserves the right to conduct unannounced audits of approved
factories at any time. Factories must allow Talbots representatives, or third parties authorized by
Talbots, unrestricted access to their facilities at all times; whether or not notification has been
issued in advance.
The factory rating system is based on the standards described in the C-TPAT Security Criteria.
Talbots C-TPAT ratings mirror the modified “traffic light” system of Social Responsibility. All audit
assessments will be reviewed and generated a rating, which will be communicated to the vendor
along with a corrective action plan (CAP). The rating and CAP will serve as a starting point for
discussion about C-TPAT compliance performance. Talbots’ ultimate goal is to work
collaboratively with vendors, factories, and buying agents to improve supply chain security.
a. Proposed Factories
As part of Talbots’ new factory introduction process to implement new factories, all import
factories will undergo a security evaluation by Talbots’ agent or Talbots nominated auditing
partner.
If the factory receives a rating below Talbots’ minimum requirements, it will not be approved
for production, but may have the opportunity to improve its rating through corrective actions
and subsequent follow-up audits to ensure security violations have been satisfactorily
addressed.
b. Active Factories
Security C-TPAT audits must be conducted at least once annually at all active factories to
verify security compliance. A timeline for corrective action will be developed and
communicated to the vendor and Talbots buying agent. Based on the audit rating and
progress of the CAP, Talbots will determine the follow-up audit schedule.
Annual audits may be conducted by Talbots buying agent and/or Talbots nominated
auditing partner.
Talbots reserves the right to prohibit or terminate business with any vendor or factory that:
• Has severely violated C-TPAT Compliance Criteria or any local law
• Is unable or unwilling to address initial audit findings
• Continues to be non-compliant after attempting to address re-audit findings
The above scenarios are reviewed by Talbots on a case-by-case basis.
c. Direct Vendors
When Talbots plans to import directly from overseas vendors, a third-party audit firm will
conduct vendor-prepaid C-TPAT security audit on Talbots’ behalf. A preliminary corrective
action plan will be prepared, which vendor and factory management are expected to agree
to; Talbots will review the audit and determine the need for any additional follow up.
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d. U.S. Based Vendors
In cases where Talbots sources from a U.S.-based vendor, an Annual Vendor Security
Certification must be completed, signed and returned to Talbots Compliance. Talbots may
require the vendor to submit a manufacturer completed Talbots security self assessment.
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VII. Chapter 2A – Talbots Supplemental Guidelines
a. Introduction
The Talbots, Inc. is committed to conducting its business in accordance with the highest
ethical standards and in accordance with internationally recognized human and labor
rights. The Talbots Supplier Code of Conduct (“Code) establishes social compliance
standards for all of our suppliers, including contractors, vendors, and agents, to ensure the
working conditions in our supply chain are safe, workers are treated with respect and
dignity, operations are environmentally responsible, and business is conducted in an ethical
manner. The Supplemental Guidelines to Talbots Supplier Code of Conduct
(“Supplemental Guidelines”) are an extension of the Code, providing detailed and
practical guidance about our expectations. These guidelines inform our suppliers,
contractors, vendors, and agents of the employment practices and working conditions
that comprise the minimum standards for doing business with Talbots.
Suppliers must always be familiar with and comply with all relevant laws and regulations.
Adherence to the human and labor rights in our Code is a prerequisite for doing business
with our company. Where the Talbots Code requirements are stricter than the law,
compliance with the Code is required.
Supplier compliance will be evaluated according to the relevant laws and regulations and
these guidelines. Talbots expects our suppliers will openly and honestly discuss any non-
compliance issue and the underlying business challenges with Talbots or our
representatives. Violations will be reported to the supplier for follow up and corrective
action. Where there are egregious violations, such as child labor, forced or prison labor,
bribery, physical abuse, and/or the supplier does not demonstrate a willingness to comply,
Talbots reserves the right to discontinue business with the supplier.
If you have any questions that cannot be answered by reviewing the Supplemental
Guidelines, please contact us via email at [email protected].
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b. Supplemental Guidelines - Compliance with Talbots’ Supplier Code of Conduct
Talbots seeks business partners who make compliance part of their day-to-day operations
by establishing affirmative measures and accountable management systems, including
effective policies and procedures, to help ensure instances of non-compliance do not
reoccur. As a measure and means of driving improvement in our supply chain, Talbots
maintains a program of regular social compliance audits. This includes initial compliance
assessments for the factories proposed for Talbots’ production, and regular evaluations for
active suppliers, on an announced or unannounced basis. As a condition of doing business
with Talbots, we expect suppliers to be cooperative and transparent during the audit
process and provide full access to the facility, workers, and records, as well as dormitories.
Documents and records provided on site must represent actual working conditions, and
employees must not be coached on how to answer questions or respond to inquiries by
Talbots or our representatives. The aim of Talbots’ evaluations is to identify problems,
establish root causes, and outline appropriate steps to achieve legal compliance and
sustainable improvement. For non-compliances with the Code and/or law, a corrective
action plan should be put in place; Talbots will monitor supplier progress towards
compliance and hold management accountable to the plan.
3
c. Policies and Procedures
Suppliers are better able to comply with local laws, Talbots Code of Conduct, and
international labor standards by implementing effective internal policies and procedures.
Therefore, suppliers are required to:
• Review and confirm internally the ability to comply with Talbots’ expectations (as
outlined in this document) and the associated actions they will take to achieve
compliance.
• Maintain current and accurate policies and procedures for each labor and
environmental provision of the Code (for example, child labor policy, age verification
procedures, waste management policy and procedures, etc.), and designate staff
responsible for implementing these policies, procedures, and related improvements.
Documentation should be available upon request to demonstrate effective
implementation of these policies and procedures and legal and Code compliance.
• Conduct internal assessments on a regular basis to ensure conformity to legal and
regulatory requirements and the Talbots Supplier Code of Conduct. Supplier must also
have a corrective action process for improvement of deficiencies identified by internal
or external assessments, inspections, investigations, and reviews.
• Ensure compliance with all legal changes (e.g., to the local minimum wage) and work
with factory staff to ensure the necessary changes are made to policies and procedures
in a timely manner to ensure compliance with the law.
• Train managers, staff, supervisors, and workers on the supplier’s Code of Conduct and/or
Talbots Supplier Code of Conduct; ensure all legally required notices are posted in the
factory at a central location.
• Establish a formal grievance system, including grievance procedures. The system should
be properly implemented, communicated at all levels, and allow for anonymity. Issues
should be reviewed by management upon receipt, discussed and responded to with a
sense of urgency, and properly filed with the issue and resolution.
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d. Child Labor
Suppliers must comply with the minimum employment age and minimum compulsory
education level defined by national law or by the International Labor Organization
(not less than 15 years of age, subject to exceptions allowed by the ILO and national
law), whichever is higher. Suppliers must obey all legal requirements for work of
authorized minors, particularly those pertaining to hours of work, wages, minimum
education, and working conditions.
- Talbots Supplier Code of Conduct
Supplemental Guidelines
• All employees must be at least 15 years of age or meet the minimum legal working age of the
country, whichever is higher. Proof of age documentation is obtained and validated prior to
an employee’s start date.
• Suppliers’ hiring policy specifies minimum employment age restrictions that are compliant with
child labor provisions under the law and with Talbots Supplier Code of Conduct.
• Suppliers maintain a personnel file for each worker that includes, at a minimum, a copy of the
best age verification documentation available in the country of manufacture (for example,
government identification cards, passports, travel documents, social insurance cards, etc.) as
well as a recent photo. Where relevant documentation is difficult to obtain or unreliable,
suppliers use an appropriate and reliable assessment method to confirm employees meet the
minimum legal working age.
Young Persons/Minors
• Young Person is defined as any worker over the age of a child as defined above and under
the age of 18.
• Suppliers follow the law or ILO Conventions 138 and 182, whichever is stricter, with regard to
type of work performed by minors, including prohibitions on night shifts and hazardous work;
working hour limits; and annual medical checkups. Suppliers take all necessary precautions to
ensure that minors are protected from working conditions likely to endanger their health,
safety, or their moral integrity, and/or which harm their physical, mental, spiritual, moral, or
social development.
• Where required by law, the supplier is responsible for the expenses associated with registering
young workers with the local bureau and ensuring young workers receive any required
occupational health and safety education, training, and physical examination, and to
maintain documentation to demonstrate compliance.
• Suppliers maintain a list of workers who are restricted by their age to certain hours and
operations; the list includes the workers’ names, employee ID number, position, and the legal
restrictions on their work activities.
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e. Forced Labor
Suppliers must not use any type of forced or involuntary labor, whether prison,
indentured, bonded, or other compulsory labor, and must ensure there is no forced
labor or human trafficking in their supply chains.
- Talbots Supplier Code of Conduct
Supplemental Guidelines
• Suppliers have a policy expressly prohibiting forced, bonded, indentured and prison labor.
• Suppliers do not use prison and/or detained labor in any form.
• All work, including overtime, is voluntary and freely chosen by workers, and not obtained
through the use of any form of force, fraud, or coercion.
• Suppliers ensure workers are not forced to work against their will, ability, or in a manner outside
of the provisions of a lawful labor contract.
• Suppliers pay all wages promptly and in full.
• Workers are allowed to freely move within the facility to use the toilets, drink water, take
designated breaks, and leave the facility at the end of their shift or after giving the employer
reasonable notice. Such movement is allowed without intimidation from supplier personnel or
security guards.
• Workers are free to refuse to perform tasks that they reasonably believe to be hazardous
without penalty of termination.
• Workers are able to leave the facility before the end of their shift under extenuating
circumstances, such as personal or family emergencies or illness, without fear of disciplinary
action, discrimination, or termination.
• Where required by law, supplier signs a written labor contract with workers to establish a labor
relationship within one month after the date the worker enters the factory. Where contracts
are not required by law, supplier provides documentation to verify workers have been made
aware of and agreed to the conditions of their employment, and provided with a written
summary or a company handbook of key terms and conditions of employment. This
information should be communicated verbally if needed.
• A worker may dissolve his labor contract by giving 30 days’ notice in writing to the factory.
• Signed employment contracts should include the information outlined below:
o Duration of the contract
o Minimum wage rates and overtime wage rates to be paid. Unless mandated otherwise by
law, these rates should be the same as the rates paid to local workers in the same job
category.
o Estimated minimum net pay that the worker can expect to receive per month.
o Maximum allowable voluntary overtime hours, consistent with the laws of the host country
and The Talbots Inc. Merchandise Supply Chain Code of Conduct.
o All benefits to be provided (including medical coverage, sick leave, annual leave and
holidays).
o All deductions to be taken (including deductions for food and housing).
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o All recruitment fee restrictions (including all administrative and processing fees and any
other amounts paid to secure employment in the home country), if imposed by host or
home country laws.
o Amount of any return fee to be refunded to any worker who paid any recruitment fees to
obtain employment and who returns to his/her home country without completing the
contractual term, regardless of reason. The return fee will equal the estimated average
recruitment fees incurred by workers in their home country, less a pro rata portion based
on the actual duration of stay vs. the contractual term.
o Summary of living conditions, including any curfews.
o When foreign contract workers are used, employment contracts must be in workers’ native
language and executed in his or her home country; the original contract belongs to the
worker.
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f. Foreign Contract Workers
When a supplier employs foreign contract workers – defined as workers who sign an
employment contract to work at a factory outside their home country – Talbots
expects vendors and factories to take special care to protect these workers’
fundamental rights of liberty and movement, guarantee equitable treatment, and
ensure foreign workers are aware of their rights under the local law. In addition to
adhering to the guidelines outlined under Forced Labor, Talbots requires the following
with respect to foreign contract workers.
- Talbots Supplier Code of Conduct
Supplemental Guidelines
• Suppliers pay all host country fees and costs, including any levies, visa, work permit, renewal
fees or other costs associated with the use of foreign contract workers. Suppliers are responsible
for all transportation costs from the home to the host country.
• Suppliers do not restrict the movement of workers by controlling identity papers (passports, work
permits, etc.), withholding monetary deposits (personal protective equipment, uniform,
working tools, etc.), requiring excessive fees, etc. Workers have full control over their passports
and other identity documents. Suppliers obtain written consent before holding passport or
other documents for any employee. Where a supplier has written consent from a worker to
hold his/her documents, supplier immediately returns the documents to the worker upon
request. Otherwise, supplier only maintains photocopies of workers’ IDs for employment
records.
• Suppliers do not use salary deductions or withholdings as repayment of a bond or payment to
a third party. Suppliers do not employ tactics to prevent workers from leaving at will, such as
withholding salary for a “year-end bonus,” or charging “guarantee money,” recruitment fees,
or imposing a penalty when a worker terminates his/her contract. Suppliers do not charge
back or accept reimbursement from any foreign contract worker to recover any fees paid by
the supplier in the recruitment of hiring said worker.
• Suppliers only use recruitment agents or firms that are legally registered/licensed in the sending
and receiving countries of foreign workers. Suppliers take all reasonable steps necessary to
ensure that it does business with reputable agencies that do not charge workers fees in excess
of what is legally permitted by any applicable law of the host or home country. Suppliers
maintain a written agreement with the agency/agencies expressly requiring that total fees
paid by the worker must not exceed any such legal limits.
• Suppliers are responsible for ensuring that each foreign contract worker is eligible to work in the
country and receives an employment contract.
• Suppliers may not impose any additional terms or requirements on the workers after the
employment contract is signed (“contract switching”), unless expressly required by law.
8
• For any foreign contract worker who wishes to leave the factory for any reason and at any
time, the supplier must arrange and pay for the worker’s airfare and/or other reasonable
transportation costs home. Supplier pays to the worker any wages, benefits or other amounts
due and owed to the worker. These are provided to the worker at the same time as his or her
return to the home country.
• Suppliers maintain and make available to Talbots or its representatives upon request current
lists of all foreign contract workers employed at the factory, including the date of arrival,
contract duration, and anticipated date of return to their home country.
9
g. Discrimination
Discrimination in employment, including hiring, pay, benefits, job assignments, working
conditions, training, recruitment, promotion, discipline, termination, and retirement,
on the basis of gender, race, religion, age, disability, sexual orientation, gender
identity, parental status, pregnancy, nationality, political affiliation, and social or
ethnic origin is prohibited.
- Talbots Supplier Code of Conduct
Supplemental Guidelines
• Suppliers expressly prohibit discrimination in hiring, compensation, training opportunities,
promotion, termination, and retirement.
• Suppliers do not show any form of discrimination toward workers who are members of a trade
union.
• Suppliers do not retaliate against an individual for filing a charge of discrimination, participating
in an investigation, or opposing discriminatory practices.
• Suppliers do not question prospective workers about their pregnancy status. Pregnancy tests
may not be conducted before hiring or as a condition of employment.
• Suppliers ensure women returning from maternity leave are given an equivalent position and
equal pay.
• Suppliers do not use medical examinations to prevent a worker from being hired or fire a worker
who becomes ill or injured.
• Suppliers’ hiring notices do not specify discriminatory factors, such as gender or race.
10
h. Freedom of Association
Suppliers must recognize and respect the rights of employees to lawfully associate
and to bargain collectively. Suppliers may not interfere with, obstruct, or prevent
legitimate related activities, and must ensure workers are not intimidated, harassed,
or penalized for the non-violent exercise of their right to join or refrain from joining any
organization.
- Talbots Supplier Code of Conduct
Supplemental Guidelines
• Suppliers recognize freedom of association and the right to collective bargaining. Where
restricted by law, suppliers establish policies and procedures providing for parallel means of
worker organizing.
• Suppliers do not interfere with workers’ activities to associate or organize and respects the rights
of workers to join or refrain from joining the trade union, seek representation, and to bargain
collectively. Prohibited practices include, but are not limited to, employee termination and/or
denial of promotion or benefits to workers who try to join a trade union or bargain collectively.
• Where the right to freedom of association and collective bargaining is restricted under law,
suppliers do not hinder the development of parallel means for independent and free
association and bargaining.
• Suppliers do not interfere with lawful activities of trade union representatives.
• Where a collective bargaining agreement exists, suppliers comply with all contractual
provisions.
• Managers are trained on respect for freedom of association and the effective right to
collective bargaining.
• Workers have the right to be collectively represented by representatives they elect, or, when
appropriate, appointed by their trade union. Suppliers do not discriminate against worker
representatives and ensure they have regular access to company management in order to
address grievances and other issues.
• Workers are able to communicate openly with management, on their own or through a worker
representative, regarding working conditions without fear of reprisal, intimidation, harassment,
or discrimination.
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i. Harassment and Abuse
All workers must be treated with dignity and respect. No worker may be subjected to
physical, sexual, psychological, or other forms of mental or physical coercion,
harassment, abuse, or intimidation. Suppliers are expected to implement reasonable
procedures for disciplining and/or terminating workers and maintain documentation
to demonstrate compliance. The use of fines as a disciplinary practice is prohibited.
- Talbots Supplier Code of Conduct
Supplemental Guidelines
• Suppliers have standardized rules/regulations and policies and procedures on acceptable and
unacceptable disciplinary practices, and clearly communicate these to management and
employees. All disciplinary actions are documented to demonstrate compliance.
• Physical abuse or discipline, the threat of physical abuse, sexual or other harassment, verbal
abuse, or other forms of intimidation are prohibited. This includes, but is not limited to:
o Physical harassment or abuse: Use or threatened use of the any form of violence.
o Verbal abuse: Shouting, threatening, or using humiliating words towards a worker;
threatening explicitly or implicitly to withhold employees’ wages, benefits, access to food,
opportunities for advancement and employment.
o Sexual harassment and abuse: Unwelcome sexual advances, requests for sexual favors,
and/or other verbal or physical conduct of a sexual nature. Examples: Requiring any form
of sexual favor in exchange for beneficial treatment in employment, or as a condition of
maintaining employment; touching workers in any way that could be considered to have
sexual implications; and making inappropriate sexual comments to workers.
o Mental abuse: Use of words or action that are reasonably understood by a worker as
demeaning.
• Suppliers ensure the confidentiality of the grievance process to protect employees from
retaliation for reporting harassment or abusive behavior.
• Body searches, if necessary, may not be conducted by the opposite sex.
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j. Health and Safety
Conditions in all production facilities must be safe, clean, healthy, and consistent with
all applicable laws, regulations, and supplemental guidelines of this Code, to avoid
preventable work-related accidents and injuries. Supplier-provided employee
housing, bathing, and toilet facilities must be safe, clean, and adequate to the
number of employees. Where higher than the law or the Code requirement, suppliers
should implement industry best practices.
- Talbots Supplier Code of Conduct
Supplemental Guidelines
General Health and Safety
• Suppliers comply with all applicable laws and regulations on occupational health and safety
in its operations.
• Suppliers keep abreast of industry operational best practices and must have a policy and plan
to achieve higher standards on a continuous improvement basis.
• Suppliers ensure all workers receive formal training in general safety procedures, and ensure
workers are appropriately trained and supervised to perform their jobs safely. Suppliers provide
workers with appropriate training on dangerous machinery.
• Suppliers appoint at least one qualified occupational health and safety expert (by education
or experience) responsible for governing health and safety in the workplace and/or residential
facilities.
• Suppliers establish an EHS committee with at least 50/50 representation by employees and
management (Note: Managerial/ supervisory representation shall not be in ratio greater than
employee representation, e.g. 60 managerial /40 employees.)
• Suppliers conduct regular monitoring to check that health and safety procedures are being
followed.
• First-aid kits are provided as recommended by the local medical provider or as required by
law and must be kept in sanitary condition and contain no expired items. Depending on the
risk and size of the factory, each production area/shift has an adequate number of workers
trained to treat common workplace injuries.
• All sewing machines are equipped with adequate guards (e.g. eye protection, needle guards,
pedal mats, etc.).
• Facility is kept generally clean and hygienic, in accordance with the law. This includes regular
and systematic refuse collection.
• There are a reasonable number of clean, operating toilets that offer privacy (i.e., ability to lock
doors), and a ventilation system to provide good circulation of air.
• Potable drinking water is provided to all workers; periodic testing is conducted on all drinking
water to ensure its safety.
• Food service and storage areas are kept clean and hygienic. Where required by law, suppliers
must have the necessary inspections from government health officials and must maintain
records of these inspections.
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• Suppliers have a process for hazard/risk identification and management, and provide
appropriate training for workers involved in high risk processes, such as the use of toxic
substances and dangerous machinery.
• Chemicals are properly stored and labeled with Material Safety Data Sheets (MSDS) made
available to workers in the local language.
• Flammable and combustible chemicals are segregated from oxidizing chemicals, reactive
chemicals, electrical sources, etc. (Appendix B)
• Suppliers provide emergency eyewash stations and/or showers where corrosive chemicals or
high volumes of solvents are handled and used.
• Suppliers ensure adequate ventilation where paints, chemicals, and sprays (solvents, solder,
dust) are used to prevent accumulation of flammable vapors.
• Suppliers provide appropriate personal protective equipment (PPE)/clothing for workers and
machines, and ensure workers are trained on how to use the PPE and why it is required and
critical for safety. Further, supervisors should regularly enforce its use.
• In high noise level areas, ear protection (ear plugs) is provided, potential hazards are
communicated, and worker usage is enforced in an appropriate manner.
• Machinery, equipment, and fixtures are checked regularly to ensure that they are in safe
working condition. Documentation must be maintained to demonstrate compliance.
• Suppliers maintain injury records; all significant accidents and near misses must be investigated
and reported and corrective action performed to minimize the likelihood of any re-
occurrence.
Emergency and Fire Preparedness
Suppliers ensure:
• Fire and emergency evacuation plans are communicated and diagrams in the local
language(s) are posted in various locations around the facility. The plan illustrates critical
information such as emergency evacuation routes, “you are here” mark, correct layout
direction, location of fire extinguishers and hydrants, and instructions in the local language of
what to do in the event of an evacuation.
• Evacuation drills are conducted regularly, at least annually or more often where required by
law.
• Emergency exits remain unlocked and free from obstruction at all times. Exits are kept
unlocked, open outwards, are clearly marked, and lead to the outside. Doors that are not
exits are labeled as such, i.e., “NOT AN EXIT”.
• Exit routes are not obstructed by equipment, materials, production, etc. (internally and
externally), and are regularly checked.
• The number of emergency exits is in accordance with the local law. At a minimum, or in the
absence of the law, supplier has at least two emergency exits per floor in buildings with less
than 1,000 workers and at least three exits exist per floor in buildings with more than 1,000
workers.
• Fire alarm system is audible throughout the entire facility. The system is inspected regularly and
tested in coordination with fire drills.
• Fire extinguishers are of the correct type, and with a minimum of one fire extinguisher per 100
m2 or at least two on every level if the total surface is below 200 m2
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• Fire equipment, including fire extinguishers, is easily accessible, clearly marked, and routinely
inspected to ensure they remain operational.
• Fire extinguishers are serviced every year; service date must be indicated on the extinguisher
or service reports must be available to demonstrate compliance.
• Emergency lighting is included in all stairways, and where needed, on exit routes. The lighting
is inspected regularly.
• Designated supplier personnel (workers and supervisors) are trained at regular intervals in fire
safety, the use of fire extinguishers, and how to administer the fire prevention procedures and
emergency evacuation plan.
• Emergency and other hazard signage is appropriate, clearly visible, and compliant with local
legal requirements.
• No smoking signs are posted in non-designated smoking areas including sensitive areas such
as chemical storage areas.
• Floors are kept clean from hazardous spills and materials.
• Fabric, yarn, and finished goods are appropriately stacked and stored in designated areas
away from production, evacuation routes and electrical sources.
• Electrical equipment and wiring is properly maintained and covered/insulated to prevent
exposure of wires.
• Gas cylinders are properly marked, used, inspected, stored, and secured.
• Railings guard all stairs, platforms, and elevated floors.
• Suppliers maintain a separate/standalone chemical area equipped with the appropriate fire
extinguishers, safety signs, ventilation, instructions on handling and disposal of the chemicals,
and personal protective equipment for workers.
• The generator and other heavy vibrating equipment, such as boilers, are not allowed beyond
the ground floor and must be isolated from any production area.
• No room or area in the facility shall be overcrowded as defined by the building permit, which
should indicate the maximum number of people the building is approved to hold.
• The structure of all buildings, including residential facilities provided by the supplier, is stable
and safe and does not put people in jeopardy.
• Buildings are not located near sources of high risk, such as chemical plants or filling stations.
• Building inspections must be conducted on a regular basis as per standard of practice or
country law.
• The building is approved for industrial use.
• The factory is aligned with the approved building plan, with no additional floors or external
retrofit structures.
• A valid Fire License is obtained for all production buildings and any residential facilities.
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Supplier-Sponsored Dormitories
All health and safety guidelines listed above are implemented in supplier sponsored dormitory
buildings. In addition:
• Dormitories are not attached to any production or warehouse building.
• Accommodations are generally kept clean, provide a safe, hygienic living environment for
workers, and comply with all legal regulations regarding residential facilities, where provided.
• Clean and safe drinking water is provided at dormitories and regularly tested.
• Toilet and shower facilities are kept clean and separated by gender.
• Residents have their own bed, an area for personal items, and the ability to secure belongings.
• Unless local law is stricter, suppliers follow the International Labor Organization’s (ILO) with
respect to the size of sleeping rooms: 7.5 square meters in rooms accommodating two persons;
11.5 square meters in rooms accommodating three persons; or 14.5 square meters in rooms
accommodating four persons. If a room accommodates more than four persons, the floor area
should be at least 3.6 square meters per person.
• Unless local law is stricter, suppliers should follow ILO recommendations on number of operating
toilets and showers: a minimum of one toilet, one wash basin, and one bathtub or shower for
every six persons.
• Toilets offer privacy (i.e., ability to lock doors) and a good ventilation system to provide good
circulation of air to reduce odors.
• Dormitory residents are free to come and go during their off-hours under reasonable limitations
imposed for their safety and comfort.
• Hazardous and combustible materials used in the production process are not stored in the
dormitory or in buildings connected to sleeping quarters.
16
k. Working Hours
All work must be voluntary, without threat of penalty, punishment, or dismissal. Workers
must not be required to work more than 60 hours per week (inclusive of overtime), or
more than the regular and overtime hours allowed under local law, on a regularly
scheduled basis. Workers are entitled to at least one day off in every seven-day period.
- Talbots Supplier Code of Conduct
Supplemental Guidelines
Employees may work more than 60 hours in a week so long as the supplier complies with the
following supplemental requirements:
• Working hours do not exceed 12 hours per day, 6 days per week for a total of 72 hours.
• One day off per seven day period is provided, or workers are provided another day of rest
during the week. If work must be carried out on the rest day during peak season, it cannot
occur more than once in a two week time period.
• Peak season is limited to no more than 4 months or 17 weeks distributed throughout a one-year
period. The maximum 60-hour workweek for non-peak production should be employed for at
least 8 months out of 12.
• Workers are compensated for regular and overtime hours in accordance with the law.
• Suppliers use a reliable time recording system, all hours are tracked, and time cards accurately
reflect the real working hour situation in the facility.
• The timekeeping system accurately records daily start/finish times, overtime, and rest day
hours, for all hourly and piece rate employees. Further, it allows employees to record their own
start/finish times (i.e., punch in and out for themselves) and/or be regularly confirmed by
workers’ signatures.
• Manual or electronic time cards should be used for hourly workers. For “piecework” workers,
an industry recognized system, capable of audit verification, should be used.
• Legal working hours and supplier working hours/schedules are made available to all workers.
Workers have access to their own attendance records upon request.
• Attendance records are maintained on site for at least 12 months.
17
l. Wages and Benefits
Suppliers must comply with the minimum wages and benefits required by local law or
the local industry standard, whichever is higher. Workers must be paid for overtime
hours at the premium rate legally required in the country of manufacture. In those
countries where overtime compensation laws do not exist, employees must be
compensated at least equal to their hourly compensation rate.
- Talbots Supplier Code of Conduct
Supplemental Guidelines
• Wages and benefits paid for a standard work week meet, at a minimum, national legal
standards or industry benchmark standards, whichever is higher.
• Overtime wages are paid for all time legally defined to be over the regular working hours,
regardless of whether the supplier pays according to hours worked or piece rate.
• Wages are paid in a timely manner, based on the law, and in the form of the local currency.
• Suppliers maintain a payroll register documenting payment of wages to each worker by hour,
day, month, or piece as appropriate. Payroll accurately records regular hours, overtime hours,
holiday pay, etc.
• Suppliers provide benefits as required by law, including public holidays, paid leaves, social
insurance and medical benefits.
• Irrespective of worker type (part time, student workers, etc.), all employees receive at least
minimum wage. Further, suppliers provide equal pay for same or similar jobs, based on relevant
experience.
• Suppliers provide pay slips to each employee in a language he or she understands. Information
should include pay period, payment date, total pay, regular and overtime hours and wages,
itemized deductions, and any allowances, incentives, benefits, or bonuses.
• Obligations to employees under labor or social security laws and regulations arising from the
regular employment relationship are not avoided through the use of labor-only contracting,
sub-contracting, or home-working arrangements, nor shall any such obligations be avoided
through the excessive use of fixed-term contracts of employment or through apprenticeship
schemes where there is no real intent to impart skills or provide regular employment.
• Any probationary employment period cannot exceed legal limits and a worker should have
no more than one probationary period. Once the probationary period is over, a worker’s
seniority date should be the date of entry to the facility, i.e., the start date of the probationary
period.
• During any probation period, a worker’s wages may not be less than the lowest wage paid for
the equivalent job post within the facility or less than the wage agreed upon in the labor
contract, nor may it be lower than the minimum wage standard of the supplier.
• Deductions from wages as a disciplinary measure are not permitted.
• Deductions, where legal, are reasonable and appropriate, and optional when related to
services such as accommodations, transportation, and food.
18
• Suppliers provide workers with the tools necessary to perform their jobs and may not require
workers to pay for such tools.
• Current and accurate payroll, wage and hour, and personnel files for all employees, dating
back at least 12 months or as required by law. In addition, a summary of active employees is
available upon request and includes, at a minimum, each employee’s name, address, phone,
date of birth, hire date, position, etc. Records for resigned or terminated employees should be
maintained for at least 12 months after an employee leaves the facility.
19
m. Subcontracting
Suppliers may not subcontract any operation in the manufacturing process without
prior written consent from Talbots, and only after the subcontractor has agreed to
comply with Talbots’ Code of Conduct.
- Talbots Supplier Code of Conduct
Supplemental Guidelines
• Suppliers may not subcontract any operation in the manufacturing process without requesting
and receiving written consent from Talbots; any subcontractor must agree to comply with
Talbots Supplier Code of Conduct. Subcontracting includes the use of home workers.
• Suppliers ensure subcontractor(s) managers, staff, supervisors, and workers are aware of
relevant laws and Talbots Supplier Code of Conduct requirements.
• Supplier assesses all approved subcontractors, based on Talbots Supplemental Guidelines, and
monitors progress made against any Corrective Action Plan (CAP) created to address the non-
compliance issues.
20
n. Environmental Practices
Suppliers, at a minimum, must meet all relevant local and national environmental
protection laws, and must strive to comply with international environmental
protection standards.
- Talbots Supplier Code of Conduct
Supplemental Guidelines
• In the event hazardous or polluting materials are discharged improperly, suppliers notify the
appropriate authorities and take immediate remedial actions.
• Suppliers monitor their work environment for appropriate air emission levels for chemicals and
pollution, waste management procedures, and other areas that may present hazards to
employees and the community as a whole.
• Suppliers maintain and keep up-to-date, relevant health, safety and environmental permits as
required by applicable laws and regulation, and their operational and reporting requirements
are followed accordingly.
21
o. Business Integrity
Suppliers must comply fully with the applicable laws and regulations of the countries in
which they operate. In addition, business must be carried out ethically, honestly, and
fairly. Suppliers must not, directly or indirectly, make any improper or unlawful gifts or
payments to any person, entity, or government official in connection with accepting
or performing orders for Talbots, or in an attempt to impact the objectivity of third party
representatives appointed by Talbots to carry out inspections and compliance audits.
- Talbots Supplier Code of Conduct
Supplemental Guidelines
• Suppliers should have an anti-corruption and bribery policy and procedures to prevent
employees or persons associated with its business from committing offences of bribery or
corruption.
• The offering, paying, soliciting, or accepting of bribes or kickbacks, including facilitation
payments, is strictly prohibited.
o A bribe may involve giving or offering ANY form of gift, consideration, reward or advantage
to someone in business or government in order to obtain or retain a commercial
advantage or to induce or reward the recipient for acting improperly or where it would be
improper for the recipient to accept the benefit. Bribery can also take place where the
offer or giving of a bribe is made by or through a third party, e.g., an agent, representative
or intermediary.
o Facilitation payments are small payments or fees requested by government officials to
speed up or facilitate the performance of routine government action (such as the provision
of a visa or customs clearance). Such payments are strictly prohibited.
• Suppliers may not offer compensation of any value (gifts, discounts, services, loans, facilitation
payments) to any Talbots associate, service provider, or government/political official to
influence any act or decision to secure a business advantage.
• Suppliers, representatives, and their employees comply with all applicable anti-bribery and
corruption laws.
22
p. Sanctions
Suppliers must not cause Talbots to violate U.S. and other applicable economic sanctions laws and
regulations (collectively, “Sanctions”), which are laws and regulations that restrict business with
certain countries, individuals, and entities in order to advance specific foreign policy and national
security priorities.
- Talbots Supplier Code of Conduct
Supplemental Guidelines
Suppliers should not, in the course of business related to Talbots:
• Conduct any business involving, directly or indirectly, countries or territories subject to
Comprehensive Sanctions (as defined below) unless authorized under Sanctions, or
• Engage, directly or indirectly, in any business with persons (i.e. individuals or entities) that are
designated on U.S. or other applicable restricted party lists.
The U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”), is the primary U.S.
government agency responsible for administering U.S. Sanctions. OFAC maintains four types of
sanctions programs, summarized as follows:
I. Comprehensive Sanctions U.S. persons (defined as U.S. citizens, U.S. lawful permanent
residents, persons located in the United States, and U.S.-incorporated entities and their
non-U.S. branches) cannot engage in any direct or indirect (e.g., through a third party)
transactions or dealings with any counterparty located in a comprehensively
sanctioned country, unless authorized under U.S. law.
As of February 28, 2022, the list of comprehensively sanctioned countries are CUBA,
IRAN, NORTH KOREA, SYRIA AND THE CRIMEA, DONETSK, AND LUHANSK REGIONS OF
UKRAINE. In addition to the above programs, as of February 28, 2022, OFAC is
maintaining an embargo on the Government of VENEZUELA, which when combined
with the other sanctions on Venezuela described herein, makes Venezuela a country
subject to nearly comprehensive Sanctions.
II. List-Based Sanctions - OFAC sanctions target entities and individuals designated on
OFAC’s sanctions lists, including the List of Specially Designated
23
III. Nationals and Blocked Persons (the “SDN List”) OFAC considers any entity 50% or more
owned, directly or indirectly, and in the aggregate, by individuals or entities identified
on the SDN List to be “blocked” and subject to the same restrictions as SDNs, even if
the entity is not itself designated on the SDN List.
The SDN List is available on OFAC’s website at http://www.treasury.gov/resource-
center/sanctions/SDN- List/Pages/default.aspx Other OFAC sanctions lists are found
at:http://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/Other-
OFAC-Sanctions-Lists.aspx.
VI. Sectoral Sanctions - These sanctions target specific sectors of a country’s economy.
Designated persons under the sectoral sanctions are added to OFAC’s Sectoral Sanctions
Identifications (“SSI”) List. Unlike with persons added to the SDN List, U.S. persons and
companies may engage in business with persons on the SSI List in some instances, as only
certain types of dealings are prohibited.
As of February 28, 2022, the main sectoral sanctions that OFAC imposes relate to the
Russia/Ukraine/Belarus and Venezuela sanctions programs.
Talbots, and other U.S. persons, are prohibited from providing assistance of any kind that would
facilitate transactions with sanctioned countries or persons by third parties, including referrals of
sales opportunities, approvals, or brokering. Talbots will review the identity and location of third
parties prior to dealings in order to ensure compliance with Sanctions.
24
q. Anti-Money Laundering
Suppliers must not cause Talbots to violate applicable anti-money laundering laws and regulations,
including the Currency and Foreign Transactions Reporting Act of 1970 (commonly referred to as
the “Bank Secrecy Act”), as amended by the Uniting and Strengthening America by Providing
Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (commonly referred to
as the “USA PATRIOT Act”) (all such laws, collectively, “AML Laws”).
- Talbots Supplier Code of Conduct
Supplemental Guidelines
The Company is not a financial institution or money services business, and as such, certain
aspects of U.S. AML Laws do not apply to its operations. It is the Company’s policy to comply with
its obligations under U.S. AML Laws, specifically with risks associated with third parties.
Any Supplier who suspects, in the course of business related to Talbots, that any activities or
arrangements that appear suspicious or indicative of money laundering or other unlawful
conduct should report them immediately to Talbots. Suppliers may not inform any other party,
including the third party in question, regarding any such suspicion, as doing so could be a
violation of AML Laws.
The following is a non-exhaustive list of “red flag” indicators and arrangements that may
generally be considered suspicious under AML Laws, and that may arise at any time during a
third-party relationship:
• Presentation of identifying documents that appear forged, altered, or otherwise invalid
• Multiple persons or accounts that share the same name, address, telephone number, or
other identification, but otherwise appear unrelated;
• Accounts funded by one individual or entity and then transferred to an apparently
unrelated individual or entity; and
• Financial activity that generally appears inconsistent with a third party’s stated objectives
or financial circumstances, or the Company’s understanding of the third party.
SUPPLEMENTAL GUIDELINES
APPENDIX A: DEFINITIONS
Bonded Labor
Work for an employer not for compensation received by the worker, but to pay off a debt, which is
often incurred by another worker offering the worker’s labor in exchange; a form of forced labor
Collective Bargaining
The negotiation of wages and other conditions of employment by an organized body of
employees, often a trade union
Corrective Action
A corrective action is a change implemented to address a weakness or non-compliance identified
in an audit. It is the action taken to correct any non-compliance which has been found in an
assessment to an agreed standard.
Corrective Action Plan (CAP)
The document completed after the audit which confirms the findings and any agreed necessary
corrective actions that must be improved to meet Talbot’s compliance standards and/or local law
Excessive Fees
Fees charged to a worker in excess of the amount legally permitted by any applicable law of the
host or home country, or, in the absence of such law, fees substantially above the prevailing market
rate
Freedom of Association
The principle of freedom of association and the effective recognition of the right to collective
bargaining guarantees to workers the right to join or form an organization of their own choosing
and to act together to protect their own economic interests. When protected by law in the
country in which merchandise is manufactured, workers must be able to carry out trade union
activities without interference from their employer or from public authorities.
Forced Labor
All work or service that is extracted from any person under the menace of any penalty for which
said person has not offered him/herself voluntarily; work or service demanded as a means of
repayment of debt (see bonded labor). The fact that the worker receives a salary or a wage is
irrelevant to determine if a situation can be considered as forced or compulsory labor.
Grievance Procedures
A process or procedure for workers who may feel that they have been treated unfairly to voice
their concerns without fear of repercussion
Harassment
Any offensive conduct or actions, whether physical, verbal, sexual, or psychological in nature, that
threatens human dignity and worker morale
Hazardous Work
Hazardous work includes working with dangerous machinery/ equipment (e.g. knives, saws);
chemicals or hazardous substances; noisy environments; lifting heavy things; extreme cold or hot
conditions. Hazardous work is one of the worst forms of child labour, as defined in ILO Convention
No. 182. For details on Children in Hazardous Work, click here.
Human Rights
A set of principles defined in the Universal Declaration of Human Rights (1948), based on the
recognition of the inherent dignity and the equal and inalienable rights of all members of the
human family as the foundation of freedom, justice and peace in the world
Indentured Labor
Work performed on behalf of an employer who forbids workers from leaving employment at the
worker’s discretion
International Labor Organization (ILO)
The ILO is the international organization responsible for drawing up and overseeing international
labor standards. It is the only 'tripartite' United Nations agency that brings together representatives
of governments, employers, and workers to jointly shape policies and programs promoting Decent
Work for all.
ILO Convention No. 138 on the Minimum Age for Admission to Employment and Work
This Convention was adopted in 1973 by the International Labor Organization. It requires ratifying
states to pursue a national policy designed to ensure the effective abolition of child labor and to
raise progressively the minimum age for admission to employment or work. For details on ILO
Convention No. 138, click here.
ILO Convention No. 182 on the Worst Forms of Child Labor, 1999
Convention No. 182 helped to focus the international spotlight on the urgency of action to
eliminate as a priority, the worst forms of child labor, without losing the long term goal of the
effective elimination of all child labor. Click here for details on ILO Convention No. 182.
Juvenile Worker (or “Minor”)
Any worker over the age of a child as defined by local or national law and under the age of 18
Material Safety Data Sheet (MSDS)
A material safety data sheet is a form that references the properties of a substance and proper
handling instructions. A MSDS is not intended for general consumer use, but rather
industrial/manufacturer users and safety personnel that may come in direct contact of the
substance. MSDS forms may contain detailed information such as physical property data, health
effects, first aid, storage recommendations, disposal requirements, necessary protective equipment
for handling, and instructions on how to handle spills, etc.
Piece Rate
A method of paying workers by the number of items they produce, rather than the number of hours
they work
Subcontractor
A business, individual, or group of individuals to whom a supplier outsources the manufacture of a
product or part-product
Trade Union (or “Union”)
An organization of workers that promotes and protects the interests of its members in issues such as
wages and working conditions, especially through collective bargaining negotiations with
employers
SUPPLEMENTAL GUIDELINES
APPENDIX B: POCKET GUIDE TO CHEMICAL HAZARDS
Chemical Name Fire
Hazard Category Potential uses Target Organs/Health Hazards /Routes Chemical type
Acetic Acid Y Combustible Reagent, used in
washing
Eye, skin, nose, throat irritation; eye, skin burns;
skin sensitization; dental erosion; black skin,
hyperkeratosis; conjunctivitis, lacrimation
(discharge of tears); pharyngeal edema,
chronic bronchitis
Colorless liquid or crystals
with a sour, vinegar-like odor
[Note: Pure compound is a
solid below 17°C/62°F. Often
used in an aqueous
solution.]
Acetone Y Flammable
Softener, diaper rinse
ingredient, feed
additive
Eye, nose, throat irritation; headache,
dizziness, central nervous system depression;
dermatitis
Colorless liquid with a
fragrant, mint-like odor
Alcohol Methyl Y Flammable Solvent
Eye, skin, upper respiratory system irritation;
headache, drowsiness, dizziness, nausea,
vomiting; visual disturbance, optic nerve
damage (blindness); dermatitis
Colorless liquid with a
characteristic pungent odor
Ammonia Reactive
Universal reagent
diluted with water and
used in aqueous form
Inhalation, ingestion (solution), skin and/or eye
contact (solution/liquid) irritation eyes, nose,
throat; dyspnea (breathing difficulty),
wheezing, chest pain; pulmonary edema;
pink frothy sputum; skin burns, vesiculation;
liquid: frostbite
Colorless gas with a
pungent, suffocating odor
[Note: Shipped as a
liquefied compressed gas.
Easily liquefied under
pressure.]
Antistain
(Group of chemicals) Non Flammable
De-staining agent/
stain remover
Eye irritant, avoid eye contact; use eye
protection
Solution containing sodium
per carbonate and sodium
carbonate
Benzene Y Flammable
Strong oxidizers, many
fluorides &
perchlorates, nitric
acid
Eye, skin, nose, respiratory system irritation;
dizziness; headache, nausea, staggered gait;
anorexia, lassitude (weakness, exhaustion);
dermatitis; bone marrow depression;
[potential occupational carcinogen]
Colorless to light-yellow
liquid with an aromatic
odor. [Note: A solid below
6°C/ 42°F]
Bleaching Powder
Laundry Non Flammable
Bleaching agent
/washing/disinfectant
Avoid inhalation, ingestion, eye and skin
contact; irritation possible
Solid containing sodium
sulphate and alkyl aryl
suphonate
Detergent Liquid Non Combustible Used in washing
/process cleaning Eye irritant, harmful if swallowed
Viscous fluid, soluble in
water
Diesel Y Combustible Fuel Skin irritation, allergy on prolonged exposure
through physical contact
Liquid with petroleum /
hydrocarbon odor
Chemical Name Fire
Hazard Category Potential uses Target Organs/Health Hazards /Routes Chemical type
Dry Cleaning Solvent
(Stoddard solvent) Y Flammable Solvent cleaner
Eyes, nose, throat irritation; dizziness;
dermatitis; chemical pneumonitis (aspiration
liquid); in animals: kidney damage
Colorless liquid with a
kerosene-like odor
Enviro Floc Salt (Combustible) Flocculent for water
treatment etc. Skin, eye contact, mild irritation
Solid, odorless white
granules (hydrated
ammonium and calcium
nitrate)
Enzymes Non Flammable
Used in reaction for
hydrolysis of cellulose
etc.
Skin, eye irritation also irritation to mouth and
throat
Amber color liquid or solid
with characteristic order
Ethylene Dichloride Y Flammable Solvent/degreaser
Eyes, skin, kidneys, liver, CNS, cardiovascular
system, (stomach, mammary gland and
circulatory system cancer in animals)
Colorless liquid with a
pleasant, chloroform-like
odor [Note: Decomposes
slowly, becomes acidic &
darkens in color]
Ethylene Oxide Y Flammable /
Reactive Sterilizing agent
Eyes, skin, respiratory system, liver, CNS, blood,
kidneys, reproductive system (peritoneal
cancer, leukemia)
Colorless gas or liquid
(below 11°C/51°F) with
ether-like odor
Formaldehyde Combustible Preservative Eyes, respiratory system (nasal cancer)
Nearly colorless gas with a
pungent, suffocating odor.
[Note: Often used in
aqueous solution (see
specific listing for Formalin).]
Hydrochloric Acid Reactive
Reagent for process/
lab use / reaction
neutralization
Inhalation, ingestion (solution), skin and/or eye
contact, irritation nose, throat, larynx; cough,
choking; dermatitis; solution: eye, skin burns;
liquid: frostbite; in animals: laryngeal spasm;
pulmonary edema
Colorless to slightly yellow
gas with a pungent, irritating
odor. [Note: Shipped as a
liquefied compressed gas.]
Hydrogen Peroxide
(Concentrate) Oxidizer Bleach
Eye, nose, throat irritation; corneal ulcer;
erythema (skin redness), vesiculation skin;
bleaching hair
Colorless liquid with a slightly
sharp odor
Liquefied Petroleum
Gas (LPG) Y Flammable Fuel Inhalation, skin and/or eye contact (liquid)
Colorless, noncorrosive,
odorless gas when pure.
[Note: A foul-smelling
odorant is usually added.
Chemical Name Fire
Hazard Category Potential uses Target Organs/Health Hazards /Routes Chemical type
Shipped as a liquefied
compressed gas.]
Methyl Isocyanate Y Combustible Urethane mfg. Eyes, skin, respiratory system
Methyl Chloride Y Flammable Solvent CNS, liver, kidneys, reproductive system (lung,
kidney & stomach tumors in animals)
Colorless gas with a faint,
sweet odor which is not
noticeable at dangerous
concentrations. [Note:
Shipped as a liquefied
compressed gas]
Methyl Ethyl Ketone Y Flammable Solvent Eye, skin, nose irritation; headache; dizziness;
vomiting; dermatitis
Colorless liquid with a
moderately sharp, fragrant,
mint- or acetone-like odor
Methylchloroisothia-
zolinone Y Combustible Preservative Eyes, skin, respiratory system
Biocide added in PPM levels
liquid
Nitric Acid Reactive Reducing agent/
reagent Inhalation, ingestion, skin and/or eye contact
Colorless, yellow, or red,
fuming liquid with acrid,
suffocating odor. [Note:
often used in aqueous
solution. Fuming nitric acid is
concentrated and contains
dissolved nitrogen dioxide.]
Phenoxyethanol Y Combustible Preservative Eyes, skin, respiratory system Colorless oily liquid
Polydimethylsilo-xane Combustible Softener silicones None known at present
In general, inert, non-toxic,
and non-flammable; also
called dimethicone
Potassium
Permanganate Salt
Oxidizing agent,
reagent, disinfectant Possibly corrosive to eyes and skin
Solid, odorless tastes
sweetish, astringent
Soda Ash Non Combustible General usage/
washing/ reagent
Severely irritating to eyes and skin avoid
contact, avoid inhalation Whit solid odorless granules
Sodium
Bicarbonate(Baking
Soda)
Non Combustible
Leavening agent,
cleaner ingredient,
bath salt ingredient,
water softener
No potential health effects anticipated; avoid
skin/eye contact/ exposure White odorless granular solid
Sodium Chloride Salt (Non
Flammable)
Reagent/ water
softener/general use Avoid exposure to eye and skin
Solid crystalline powder with
saline taste
Chemical Name Fire
Hazard Category Potential uses Target Organs/Health Hazards /Routes Chemical type
Sodium Hydro Sulphite Salt (Combustible) Make up chemical,
reagents. Inhalation, ingestion, skin and/or eye contact
White crystals or powder
with a slight odor of sulphur
dioxide
Sodium Hydroxide Reactive Bleach/
neutralization/solvent
Eye, skin, mucous membrane irritation;
Pneumonitis; eye, skin burns; temporary loss of
hair
Non-combustible Solid, but
when in contact with water
may generate sufficient
heat to ignite combustible
materials
Sodium Hypochlorite Salt (Combustible) Disinfecting agent
Irritant of the nose and throat, causing
coughing, difficulty breathing, and pulmonary
edema
Strong chlorine odor. Clear,
greenish-yellow solution
Sodium Metabisulfite Non Combustible
Food and
pharmaceutical
preservative,, waste
water de-chlorinating
agent
Can affect respiratory system, eyes, and skin;
use personal protective equipment to avoid
Inhalation
Solid white crystal with
pungent sulphur dioxide
odor
Sodium Thiosulphate Non Flammable General usage/
Washing/ Regent
Hazardous in case of ingestion, of inhalation;
Slightly hazardous in case of skin contact
(irritant), of eye contact (irritant)
White, odorless solid
Sulphuric Acid Reactive Reagent for Process/
Lab use Inhalation, ingestion, skin and/or eye contact
Colorless to dark-brown, oily,
odorless liquid. [Note: Pure
compound is a solid below
11°C/51°F. Often used in an
aqueous solution.]
Tetrachloroethylene Y Flammable Solvent/ Degreaser
Irritation eyes, skin, nose, throat, respiratory
system; nausea; flush face, neck; dizziness,
incoordination; headache, drowsiness; skin
erythema (skin redness); liver damage;
[potential occupational carcinogen]
Non-combustible Liquid, but
decomposes in a fire to
hydrogen chloride and
phosgene
Tetrahydrofuran Y Flammable Solvent/ Vinyl Adhesive
Eye, upper respiratory system irritation;
nausea, dizziness, headache, central nervous
system depression
Class IB Flammable Liquid:
Fl.P. below 23°C/ 73°F and
BP at or above 38°C/100°F
Toluene Y Flammable Solvent/Adhesive Eye, skin, respiratory system, central nervous
system (CNS), liver, kidneys
Colorless liquid with a sweet,
pungent, benzene-like odor
Trichloroethane Y Flammable Solvent/ Degreaser Eye, skin irritation; headache, lassitude
(weakness, exhaustion), central nervous
Colorless liquid with a mild,
chloroform-like odor
Chemical Name Fire
Hazard Category Potential uses Target Organs/Health Hazards /Routes Chemical type
system depression, poor equilibrium;
dermatitis; cardiac arrhythmias; liver damage
Trichloroethylene Y Flammable Solvent Eyes, skin, respiratory system, heart, liver, CNS
(liver & kidney cancer in animals)
Colorless liquid (unless dyed
blue) with a chloroform-like
odor
Source: National Institute for Occupational Safety and Health (NIOSH)
Disclaimer: For Reference only, No Authenticity claimed. For additional Information, refer to the chemical’s Material Safety Data Sheets (MSDS)
Substances to be stored away from other substances listed
Substances not to be stored with cid
High Fire Hazard
Substances not to be stored with Acids, Oxidizers, and Bases. Have their own fire hazard-risk of fire if vapor exists in electrical fittings, hazards, spark,
etc.
No reactivity /danger known. However, in case of fire in other product situation, handle with care